Officers developed probable cause the defendant was selling controlled substances out of his parked car. The officers approached the defendant, ordered him out of the car and searched the passenger compartment. The officers found a bullet on the front seat and a pistol in the glove compartment. An officer arrested and handcuffed the defendant while other officers searched the trunk of the car. Inside the trunk, officers found a closed brown paper bag that contained heroin. The officers moved the car to the police station and searched it again, finding a closed leather pouch that contained $3,200 in cash.
Whether officers, who have lawfully stopped an automobile and have probable cause to believe that contraband is concealed somewhere within it, may conduct a search of compartments and containers that are not openly visible?
Yes. If probable cause justifies the search of a lawfully stopped automobile, it justifies the search of every part of the vehicle and its contents that might conceal the object of the search.
Because the officers lawfully detained the defendant and established probable cause his vehicle contained contraband, the officers could conduct a warrantless search of the vehicle. The search could be as thorough as one authorized by a warrant issued by a magistrate. Every part of the vehicle where the contraband might be stored could be searched. This included all receptacles and packages that could possibly contain the object of the search.
456 U.S. 798, 102 S. Ct. 2157 (1982)